Picture a morning a year from now. One of your people, instead of grabbing the rota and heading off to the van, stops in the doorway and asks you something nobody has ever asked you before: what exactly do you record about me while I work, and why. He is not angry, he is not squaring up for a fight. He is informed. And right there, on the spot, you realise you do not have an answer ready.
Today almost nobody asks that question. People clock in, they work, and when something does not add up the explanation going round is always the same: it is the system. A line that ends every conversation, because you cannot argue with a system. The trouble, for whoever runs that system, is that the line is about to stop working. Europe has decided to put in writing a principle that until yesterday was left to each employer’s good sense: anyone who works has the right to know how they are being monitored, measured and judged, especially when the one doing the judging is a piece of software instead of a person.
The push has a name, Directive (EU) 2024/2831, in force since December 2024, which every Member State has to bring into national law by 2 December 2026. In Ireland the Department of Enterprise, Tourism and Employment has already opened the assessment and a consultation, even if there is no draft bill yet. It was written for riders and platform work, but it is acting as a megaphone for an idea that touches anyone who sends someone out to do a job: opaque monitoring, the kind nobody explains to you, has its days numbered. If you are reading this from across the water, the directive does not bind the UK, you sit under the ICO and UK GDPR on a separate track, but the direction of travel is the same.
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Open your trialThe handle changes hands
What really changes is not the law in itself, it is who now holds the knife by the handle. For years monitoring was a one-way game: the one running things knew, the one working put up with it, and anyone who asked for an explanation got the silence of the algorithm. Now it flips. The worker who informs himself, and he will, stops being the one who has to justify where he was at four in the afternoon, and becomes the one who asks you why you, at four in the afternoon, knew where he was.
And this is where most of the systems out there come unstuck, because they collect far more than the job needs: position non-stop, routes, stops, dead time. Stuff you will never look at, until one day somebody else does. Quietly tracking your people all day long is a bit like reading the phone of the person asleep beside you: even when you find nothing you have already lost, because you sat down to look. And in front of an informed worker, or worse in front of the DPC, the line “I only wanted to know if they were working” sounds exactly like “I only wanted to have a quick look”.

Most of it is already law, it is not waiting for 2026
Worth dropping an illusion here: to land in trouble you do not even need to wait for the directive to be transposed, because the bulk of this is already on the books. GDPR already requires you to collect only the data you genuinely need, to keep it for the right length of time and not a minute longer, and to tell people plainly what you are doing with their data. That is not a 2026 problem, it has applied since 2018.
And it is not conference-room theory. Ask Doolin. In the case the Irish Court of Appeal decided in 2022, an employer had CCTV at the entrance purely for security, looked at the footage to investigate vandalism, spotted an employee in the break room outside his break, and used that to discipline him. The court ruled the use unlawful: data gathered for one stated purpose, security, cannot be quietly repurposed to monitor a worker’s hours. Notice the shape of it. There was no covert tracker, no GPS, just footage taken for one reason and bent to another. That is the trap most monitoring setups walk straight into.






